July 11, 2020

Volume X, Number 193

July 10, 2020

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July 09, 2020

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CCPA Final Proposed Regulations Filed

The California Attorney General submitted the final proposed California Consumer Privacy Act (CCPA) regulations on June 1, 2020 to the California Office of Administrative Law (OAL) for review. According to the Attorney General’s submission, OAL has thirty working days to review the regulations, plus an additional sixty calendar days under the Governor’s Executive Order N-40-20 related to the pandemic, to review the regulations for procedural compliance under the Administrative Procedure Act. These are the last steps in the process of finalizing the CCPA regulations by the July 1, 2020 effective date. The entire list of documents submitted to OAL can be found here.

The Attorney General, in a statement filed with the regulations, requested expedited review of the regulations, despite the additional time provided by the Executive Order. The statement cited the CCPA’s July 1, 2020 statutory deadline to finalize the regulations and described the lengthy and extensive rulemaking process undertaken by the Attorney General’s Office. The statement requested that the OAL complete its review of the regulations within thirty business days so that enforcement can begin on July 1. The statement also said that once the final regulations are adopted, the Attorney General will begin enforcement of the regulations and will provide guidance to businesses for how to comply.

We will be reviewing the regulations in detail over the next several days so stay tuned for a more detailed analysis of the final regulations. We will also be looking forward to guidance from the Attorney General to businesses regarding compliance with the law and regulations.

Copyright © 2020 Robinson & Cole LLP. All rights reserved.National Law Review, Volume X, Number 156


About this Author

Deborah A. George, Robinson Cole, Cybersecurity lawyer

Deborah George is a member of the firm’s Business Litigation Group as well as its Data Privacy + Cybersecurity Team.

Deb advises clients on and focuses her practice on data privacy and security, cybersecurity, and compliance with related state and federal laws. She also has experience providing counsel in civil litigation and employment law matters.  She has significant experience offering advice and counsel on legal issues related to human services agencies, including Medicaid, as well as  drafting and reviewing contracts, business associate agreements, and data use agreements. ...